Expert Analysis

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal

At the beginning of 2013, and after having had a very hard time trying to convince businesses to support the 2012 tax reform, the government promised that it would file a comprehensive tax reform to better articulate the tax system and in this way avoid the need of making reforms every other year to deal with budget constraints, writes Jaime Vargas, tax managing partner and international tax services leader at EY Colombia.

The past three years have seen significant changes to the Colombian tax framework, generally constituting a convergence with international tax concepts. Ximena Zuluaga and Luis Orlando Sánchez, of EY, explore the changes introduced by the 2012 tax reform and associated regulations released at the end of 2013 and assess the scope for further reform measures.

John Henshall and Achim Roeder explain why it would be unwise to underestimate the impact of business restructuring. The impact extends to the discussion on the revision of chapter VI of the OECD transfer pricing guidelines on intangibles.

Antonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Rodrigo Winter of PwC Chile outlines the expected effects of the government’s proposal aimed at reviving a residential real estate sector weakened by years of stagnation

Several key rulings clarify the taxation of cross-border payments as royalties with respect to ‘information concerning industrial, commercial or scientific experience’, say S Vasudevan, Prachi Bhardwaj, and Prakhar Pandey of Lakshmikumaran & Sridharan

Michael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept